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Extracted Text (OCR)
Cas@€ds20kcr0680422P G Bo fionemsaes Fileday MGAd2 Pageagef@of 11
COUNT FIVE
(Attempted Sex Trafficking of Minor Victim-4)
The Grand Jury further charges:
Be At least in or about September 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a “Jay
Barnes,” a/k/a “Brent English,” the defendant, in or affecting
interstate and foreign commerce, attempted to recruit, entice,
harbor, transport, provide, obtain, advertise, maintain,
patronize, and solicit a person who had not attained the age of 14
years at the time (“Minor Victim-4"), knowing, having had a
reasonable opportunity to observe, and in reckless disregard of
the fact that Minor Victim-4 had not attained the age of 14 years,
and knowing that Minor Victim-4 would be caused to engage in
commercial sex acts, to wit, ENGLISH attempted to recruit, entice,
transport, and obtain Minor Victim-4, an eleven-year-old
girl, to engage in sexual acts with at least one man in exchange
for money, some of which ENGLISH would keep for himself.
(Title 18, United States Code,
Sections 1594(a), 1591(a){1) and {(b) (1), and 2.)
COUNT SIX
(Attempted Sex Trafficking of Minor Victim-5)
The Grand Jury further charges:
6. At least in or about October 2013, in the Southern
District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a “Jay
Barnes,” a/k/a “Brent English,” the defendant, in or affecting
DOJ-OGR-00006017